How the Rosa Protocol works: three tiers, one registered physician

Every recommendation we generate sits in one of three tiers. The tier tells you who decides: you and our templates, the AI executing a doctor-signed map, or a licensed physician reviewing your case.

The doctor decides. The AI supports.

Italian Law 132/2025 is explicit: AI may support clinical work, but the decision is always taken by a registered medical practitioner. The three tiers are how we operationalise that. Lifestyle suggestions run on doctor-signed templates. Supplement suggestions run on a doctor-signed mapping table. Anything that crosses a clinical threshold is reviewed and signed by a physician registered with the Italian Medical Board before it ever reaches you.

Tier 1: lifestyle

Pure wellness education: sleep, hydration, exercise zones, food sources of nutrients, recovery practices. The AI runs autonomously, drawing on a template library that the medical advisor signs off on quarterly. The doctor approves the library and does not see individual reports. You get plain-language tips you can apply today, with no prescription and no diagnosis.

Tier 2: supplements and retest

Targeted supplement suggestions with a retest window. Example: vitamin D below 30 ng/mL, D3 1,000-4,000 IU a day, retest in 8-12 weeks. The AI executes a fixed mapping table built and signed by an Italian-licensed doctor: category and dose range only, never a specific brand. You see a clear suggestion, the reason behind it, a retest window, and a reminder to discuss it with your physician before starting.

Tier 3: clinical referral

A biomarker crosses a clinical threshold: diabetic-range HbA1c, kidney function decline, liver enzyme elevation, a cardiac risk pattern. The AI does not give a verdict. It drafts a handoff note for the reviewing physician and flags the case in the doctor queue. An Italian-licensed physician reads the note, the markers and your history, then signs the final recommendation within 5 working days, 24 hours for urgent flags. You see the reviewing doctor’s name and Italian Medical Board number on the report.

The legal frame

• EU MDR 2017/745: Tier 1 and Tier 2 sit under the wellness exclusion. Tier 3 is the only path where clinical interpretation happens, and it is human-signed.
• Italian Law 132/2025: AI supports, the doctor decides. Every Tier-3 report is signed by a doctor registered with the Italian Medical Board.
• GDPR Art. 9 and 22: explicit consent at signup, plus a "request human review" path that sits next to every AI output.
• Italian DPA (Garante): qualified medical oversight from template design through validation.

Under GDPR Art. 22 you may request a physician review of any analysis we generate, at any time.